Privacy Policy

Introduction

This privacy policy describes the types of personal data we collect, how we use it, how and when it may be shared, and the rights and choices you have with respect to your information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your information. In this privacy policy, the terms “We,” “us,” refer to McKay Brothers, LLC, McKay Brothers International SA, Quincy Data, LLC and our respective affiliates, among whom your information may be shared. The term “Service Provider” refers to vendors, consultants, professional advisors, and other service providers working on our behalf.

This privacy policy applies to information we collect from all sources, including in connection with our website, conferences, events, electronic newsletters or communications, or in connection with the services we provide or any of our job postings that link to this privacy policy.

What information do we collect?

In this privacy policy, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal data.

Types of personal data we may collect include:

• Personal data disclosed by you. For example, we may collect information from you when you fill out our contact form, subscribe to our newsletter, send us an email, respond to a job posting on our website, register for or participate in an event, respond to a survey, interact with us on social media, or otherwise communicate with us. You are not required to provide personal data in order to view our website.
• Personal data about you disclosed to us by a Service Provider or other third party. For example, we may use a third party to recruit talent to fill any of our employment opportunities.
• Personal data about you that we collect from other sources. For example, we may use information from LinkedIn to update information about you in our contact database.
• Information automatically collected about you when you access our website. We use cookies to compile aggregate data about website traffic and website interaction so that we can offer better website experiences and tools in the future. Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your Web browser (if you allow), that enable the websites or service providers systems to recognize your browser and capture and remember certain information. You may disable cookies in your Web browser; however, it is possible that doing so may impact your ability to use our website.

How do we use your information?

Depending on how you interact with us and the services you or your organization utilize, we use your personal data to:

• Provide, activate and manage your access to and use of our services;
• Provide technical, product and other support and to help keep the service working and secure;
• Enhance and improve our website and services and to develop new products and services;
• Respond to your requests, inquiries, comments and concerns;
• Notify you about changes, updates and other announcements related to our services;
• Deliver targeted advertisements, promotional messages, notices and other information related to our services aligned with your interests;
• Communicate with you about employment opportunities;
• Assess job applications and make hiring decisions;
• Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties, such as event sponsors; and
• Comply with our legal obligations, resolve disputes, and enforce our agreements.

If you are the point of contact for an organization with an active subscription to our services, we will use your details to communicate with you about your organization’s subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the service that may include a reference to you.

When we use your personal data, there are various legal bases on which we may rely depending on what personal data we process and why. The legal bases include:

• Contract performance: where your information is necessary to enter into or perform our contract with you or the organization you represent;
• Consent: where you have given us clear consent for us to process your personal data for a specific purpose;
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your privacy rights;
• Legal claims: where your information is necessary for us to defend a claim or resolve a dispute; or
• Legal obligation: where we need to use your information to comply with our legal obligations.

How do we protect your information?

We implement commercially reasonable physical, technical and procedural measures to help protect personal data from unauthorized access or use; however, the transmission of information via the internet is not completely secure or private. If you have questions about the security of personal data we collect, please contact us using the information provided below.

Do we disclose any information to outside parties?

We may share your personal data as follows or as otherwise described in this Privacy Policy:

• with Service Providers who need access to your information to carry out their work for us. Since our Service Providers are located around the world, please note that these disclosures may involve cross-border transfers of your personal data as described in the “Data Transfers” section below;
• when we believe release is appropriate to comply with the law, enforce our website policies, or protect ours or others’ rights, property, or safety;
• in connection with, or during negotiations of, any merger, sale of our assets, financing or acquisition of all or a portion of our business to another company;
• with your consent or at your direction, including if we notify you that your personal data will be shared in a particular manner and you provide such personal data;
• when you use our Services to intentionally interact with third parties; or
• as aggregated or de-identified information, which cannot reasonably be used to identify you.

We may contract with third-party service providers to assist us in better understanding our website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the website. Google Analytics uses “cookies”. You can find out more about how Google uses data when you visit our website by visiting “How Google uses data when you use our partners’ websites or apps”, (located at www.google.com/policies/privacy/partners/). For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

Our website utilizes remarketing services through Google Adwords and other vendors to help us better serve the users of our website. Based on information that we automatically collect and information that you provide to us, Google may display targeted ads tailor made for you on outside websites based on your previous interactions with our website. You may opt out of Google Remarketing Ads on Google’s website.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website or links to other websites. Examples include Facebook, LinkedIn, and Twitter®. The privacy practices of these third parties will be governed by the parties’ own privacy notices. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy notices or policies applicable to these third-party products and/or services. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.

How long do we keep your personal data?

We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose. If your personal data is used for two purposes, we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.

What are your rights and choices?

Consistent with applicable law, you may exercise the rights described in this section. Please note that the rights may vary depending on your country or state of residence.

Opt Out of Direct Marketing:

You may opt out of receiving direct marketing communications from us by following the unsubscribe instructions at the bottom of each email, or if you are a current subscriber to our services, by changing your account settings through the customer portal.

Please note that there are certain communications we are required to send you that relate to the services or products we are providing to you or the organization you represent that you may not be able to opt out of.

Access, Correct or Delete your Personal Data

You may have the right to request access to and receive details about the personal data we maintain about you and how we process it, correct inaccuracies, or request that we delete your personal data by contacting us as indicated below. If you or the organization you represent are a subscriber to our services, you can also update your personal data by signing into the customer portal.

Withdraw Consent

Where you have provided your consent for us to use your personal data, you have the right to withdraw your consent and we will apply that preference going forward.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions and exceptions, and some of these rights might be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to deliver services to you, defend our rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, please note that we may only implement requests with respect to the personal data associated with you as an individual. We may need to verify your identity before implementing your request and will try to comply with your request as soon as reasonably practicable.

If you are receiving communications from us as part of a larger corporate email group within your own organization (e.g., info@abccorp.com), we will not have control over your individual personal data and will not be able to process your request.

Additional Information for European Economic Area Residents

If you are a resident of the European Economic Area (“EEA”) Switzerland or the United Kingdom, you have certain rights and protections under applicable law regarding the processing of your personal information. When we process your personal information as described in this Privacy Policy, we are required to have a legal basis to do so. The legal bases we use are as outlined above.

When processing is based on consent, you have the right to revoke such consent at any time. You also have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Additional Information for California Residents

If you are a California resident, this section provides information about your rights under California Law in relation to your personal data and our privacy practices. Under certain circumstances and in accordance with applicable data protection laws:

• You have the right to request that we disclose to you what information we collect, use, disclose, or sell.
• You have the right to request that we delete any personal data about you that we have collected.
• For your protection, any request we receive to delete your personal data will be subject to identity verification–which may require you to provide us with information about you to compare to information in our files. If an authorized agent submits a request on your behalf, we may confirm the request and your identity directly with you unless they demonstrate they have a power of attorney.
• You can exercise your right to stop email marketing messages from us at any time by following the unsubscribe instructions contained within each email.
• We will not discriminate against you for exercising any of the rights indicated above.
• We may have disclosed your personal data as described in this policy during the preceding 12 months to the following categories of recipients: cloud service providers (including Customer Relationship Management providers and Contract Lifecycle Management providers), consultants, data analytics providers, internet service providers, data storage providers, and operating systems and platforms. We may also have disclosed professional and employment-related information with cloud service providers and consultants.
• We do not sell your personal information.

Children’s Privacy

We provide low-latency bandwidth and market data solutions for professional trading firms. Our services are not aimed at children under the age of 18. We do not knowingly collect information from children under the age of 18.

Data Transfer Notice

We may process and store your personal information in the United States and other countries which may have less-protective data protection laws than the region in which you are situated. Please note that this processing, including storage, may involve cross-border transfers of your personal information. For residents of the EEA, Switzerland, or the United Kingdom: we provide adequate protection for the transfer of personal data to countries outside of those jurisdictions by executing Standard Contractual Clauses, as authorized under EU or UK Law. For questions regarding our use of the Standard Contractual Clauses to facilitate the transfer of personal data, please contact us using the information below.

Consent to Privacy Policy

By using our website, you consent to our privacy policy.

Changes to our Privacy Policy

We may change this policy from time to time. If we make changes, we will revise the date at the bottom of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to our website homepage or by sending an email notification). We encourage you to review this policy frequently to stay informed about our information practices and the choices available to you.

This policy was last modified on February 6, 2023.

Contacting Us

You may contact us using the information below.